2023 Physician Fee Schedule: How the Final Rule Affects Remote Therapeutic Monitoring

On November 01, 2022, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule that includes updates and policy changes for Medicare payments under the Physician Fee Schedule, and other Medicare Part B issues. These changes will take effect on January 1, 2023.

One of the most impactful outcomes of the Final Rule was the proposed changes related to Remote Therapeutic Monitoring (RTM). The Proposed Rule for Calendar Year 2023 included changes that could have cut reimbursements and impacted the future of Remote Therapeutic Monitoring for physical and occupational therapists. But thanks to campaigns supporting RTM and outreach from the therapy community, the changes and reimbursement cuts to the codes that CMS proposed were not finalized. 

This is great news for therapy advocates and their patients, and will boost the growing excitement currently bubbling up in the industry around RTM. In their summary of RTM comments in the Final Rule, CMS noted an abundance of interest and support among providers. Many private practices and outpatient providers who have yet to embrace RTM are now taking steps to get set up for next year, and hospitals are starting to pick up interest in the impactful program.

Here is how the Final Rule will affect Remote Therapeutic Monitoring in 2023, and what it will mean for your organization.

New codes were not created for physicians as proposed

In the Proposed Rule, CMS wanted to create 4 new “G-codes”: GRTM 1 through 4—two for physicians and non-physician practitioners and two for non-physician healthcare professionals, like PTs and OTs. These codes would have replaced 98980 and 98981 to bill for RTM treatment management services. There would have also been significant payment cuts for RTM services provided by PTs and OTs under the new codes.

However, in the Final Rule, the new G-codes were not finalized. All eligible providers will continue to bill CPT codes 98980 and 98981.

Payments were maintained instead of cut

Under the same proposed G-codes, there would have also been significant payment cuts for RTM services eligible for providers in non-facility based settings, like PTs and OTs in private practice.

In the Final Rule, all eligible providers will now continue to bill CPT codes 98980 and 98981 at the same reimbursement rates, due to staff inputs remaining in the practice expense part of the CPT codes.

Requirements were eased instead of increased

In the Proposed Rule, CMS suggested requiring 98975, 98976, or 98977 to be billed before 98980 or 98981 could be billed, requiring the 16 days of data threshold to be reached before RTM could receive any reimbursement. However, those changes were not finalized. CMS has indicated, therefore, that 98975, 98976, or 98977 can be billed independently of when 98980 or 98981 are billed, giving providers more flexibility in their billing process. 

Updates to Supervision

Where the practitioner’s Medicare benefit does not include services furnished incident to their professional services, the services described by the codes must be furnished directly by the billing practitioner or, in the case of a PT or OT, by a therapy assistant under the billing PT’s or OT’s supervision

These practitioners could bill CPT codes 98980 and 98981 even when the practitioner’s Medicare benefit category did not include services furnished incident to their professional services as long as the services were furnished directly by the billing practitioner.

Virtual direct supervision has been extended by CMS to the year that the PHE ends (renewed until Jan. 11 2023)—so at least until the end of 2023.

Additional Remote Therapeutic Monitoring Resources

[Guide] Your Guide to Boosting Revenue and Patient Retention with Remote Therapeutic Monitoring
[Infographic] Understanding the RTM Clinician Workflow
[Article] Remote Therapeutic Monitoring: Your Questions Answered, Part 1

[Article] Remote Therapeutic Monitoring: Your Questions Answered, Part 2

[Article] MedBridge Roundtable: Insights from Organizations Using the MedBridge Remote Therapeutic Monitoring Solution

How MedBridge can help with Remote Therapeutic Monitoring

Our Patient Engagement Solution allows providers to perform remote therapeutic monitoring by digitally assigning programs to patients with musculoskeletal, respiratory, and other conditions. Providers can then monitor non-physiologic patient data, including program adherence, pain levels, and patient feedback; communicate with patients between sessions using in-app messaging and virtual visits; and adjust the program as needed to optimize patient outcomes.

Our effective, evidence-based solution satisfies the FDA requirements for a medical device and is eligible to be used for patient monitoring. It integrates MedBridge’s Home Exercise Program, Patient Education, Patient Mobile App, Adherence Tracking and Reporting, Telehealth Virtual Visits, and Net Promoter Score for monitoring and improving patient satisfaction.